Tradeshift, Inc. v. Smucker Services Company
- Edgardo Ramos
- 1:20-cv-03661
- U.S. District Court · Southern District of New York
- 2
In Tradeshift v. Smucker, Judge Ramos granted Smucker’s request to seal redacted portions of two exhibits containing confidential vendor-selection information.
Smucker Services Company’s court filing and public access to the redacted portions of its vendor-selection documents were affected; the order also concerned information covered by a confidentiality agreement with Tradeshift, Inc.
What happened
In Tradeshift, Inc. v. Smucker Services Company, Smucker asked to file redacted portions of a request for proposals and business requirements documents under seal. The documents were to be exhibits supporting Smucker’s opposition to Tradeshift’s motion to dismiss Smucker’s counterclaim.
Smucker said the documents contained sensitive information about its internal vendor-evaluation process, business and technical needs, and information covered by a confidentiality agreement with Tradeshift. It argued that public disclosure could give potential vendors an unfair advantage.
Judge Edgardo Ramos granted Smucker’s request to file the redacted portions of the two exhibits under seal, finding that the need to protect confidential business information outweighed the presumption of public access.
The detailed version
- Tradeshift, Inc. v. Smucker Services Company · No. 1:20-cv-03661
- Edgardo Ramos
- Oct. 9, 2020
Background
Smucker Services Company requested permission to file under seal redacted portions of two documents: a Request for Proposals and Business Requirements Documents. The documents were referenced in Smucker’s counterclaim but were not attached to it. Smucker intended to file them as Exhibits A and B to the declaration of Chelsea Mikula in support of its opposition to Tradeshift, Inc.’s motion to dismiss Smucker’s counterclaim.
Sealing request
Smucker argued that the documents contained sensitive and proprietary information about its internal process for evaluating potential vendors, including confidential information about its business and technical needs. Smucker also stated that the documents contained information covered by a mutual confidentiality agreement between Smucker and Tradeshift. It argued that disclosure could substantially harm Smucker by giving potential vendors an unfair advantage in understanding how Smucker conducts its procure-to-pay system.
The court applied the standards governing requests to seal court documents. Those standards require the court to consider whether the materials are relevant to the judicial function, weigh the presumption of public access, and determine whether sealing is essential to protect a higher interest and is narrowly tailored to that interest.
Ruling
Judge Edgardo Ramos granted Defendant’s request to file under seal the redacted portions of Exhibits A and B. The order states that Smucker’s interest in protecting confidential and proprietary information outweighed the presumption of public access. The order addressed only the filing of the redacted exhibits and did not decide the parties’ underlying claims or Smucker’s counterclaim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.